SECTION 7. DATE OF

APPLICABILITY

This revenue procedure applies to any management contract that is entered into on or after January 17, 2017, and an issuer may apply this revenue procedure to any management contract that was entered into before January 17, 2017. In addition,

an issuer may apply the safe harbors in Rev. Proc. 97–13, as modified by Rev. Proc. 2001–39 and amplified by Notice 2014–67, to a management contract that is entered into before August 18, 2017 and that is not materially modified or extended on or after August 18, 2017 (other than pursuant to a renewal option as defined in § 1.141–1(b)).